Corporate Travel Policy

1. GENERAL POLICY REQUIREMENTS

1.1. Purpose. All Seagate consultants, contractors, and outside representatives are responsible for controlling travel and entertainment expenses, and are expected to use good judgment when requesting reimbursement from Seagate.

1.2. Scope. This policy covers all contractors and contractor personnel who are authorized to incur expenses that will be reimbursed by Seagate. This policy applies on a worldwide basis. For non-US operations, this policy may be subject to additional terms or modifications to meet local requirements within the individual country.

1.3. Authorization. This policy does not authorize Contractor to incur any expense on behalf of Seagate. This policy defines the type of expenses that can be reimbursed, if authorized, and the procedures for obtaining reimbursements. All contractors must obtain advance authorization from Seagate before incurring any travel or entertainment expense, and must obtain reauthorization if there is any change in the expenses after the original authorization.

1.4. Policy Exceptions. Any exception to this policy will be considered a deviation and will require the written approval of the responsible Seagate Vice President for deviations up to US$500 or a Senior VP or above for deviations exceeding US$500. NOTE: There are no exceptions for vehicle violations or for violations of customs and export control requirements.

2. AIR TRAVEL

2.1. Lowest Logical Airfare. Contractor's personnel traveling via air carrier are expected to accept flights with the lowest logical airfare. The "lowest logical" airfare means that Contractor cannot use a more expensive flight if there is a less expensive flight available that meets following requirements:

Does not change the departure or arrival time by more than 2 hours.

Does not increase the one-way total elapsed trip time by more than 2 hours.

Does not add more than one additional stop each way.

Provides savings of at least 20% or more (minimum US$100) off the cost of the round trip air ticket.

May use alternative carriers or airports (i.e., regional discount carriers or secondary airports).

2.2. Class of Travel. All travelers must fly in coach or economy class unless the traveler obtains an exception in advance from the applicable Senior VP.

A traveler may fly in business class or first class when traveling with a Seagate VP or above for the purpose of conducting Seagate business with the VP. This exception is available only at the request of the VP and must be approved in advance by the applicable Senior VP.

A traveler may fly in business class or first class when traveling with a customer or potential customer who is traveling in business class or first class. This exception must be approved in advance by the applicable Senior VP.

2.3. Unauthorized Upgrading. Upgrading air tickets to a higher class of service without the advance written approval of a Senior VP is considered a personal expense and will not be reimbursed by Seagate.

2.4. Unauthorized Downgrading. A traveler may not downgrade air tickets to subsidize personal travel or to subsidize travel for accompanying individuals. If the air carrier downgrades a ticket for any reason, the refund must be returned to Seagate.

2.5. Cancelled or Changed Reservations. If a trip is ticketed and then cancelled or changed, it is the responsibility of the individual traveler to ensure that the original ticket prices is refunded or documented and used toward future travel.

2.6. Frequent Traveler Programs. Contractor is permitted to accumulate mileage credits and other benefits from individual frequent traveler programs; however, Contractor is prohibited from selecting travel providers based on membership or benefits in any program.

2.7. Charter/Personal Aircraft. All aircraft charter requests, as well as requests to use personal or corporate aircraft, must be approved in writing by Seagate's President, Chief Financial Officers, or Chief Executive Officer.

2.8. Group Travel. If ten or more travelers are going to the same destination for the purpose of conducting Seagate business, then Contractors should coordinate with Seagate's Corporate Travel Administration for contract negotiations with airlines, lodging, and ground transportation suppliers. For further information regarding group travel, please contact Seagate's Corporate Travel Administration in Scotts Valley, California, USA.

3. GROUND TRANSPORTATION

3.1. Use of Alternative Transportation. Contractor must use the most cost-effective means of ground transportation while on Seagate business, and must evaluate alternative transportation, such as airport shuttles and taxis, before electing to rent a car.

3.2. Intermediate Size Cars Or Smaller. All travelers are expected to rent intermediate size cars or smaller. Contractor is responsible for ensuring that the proper rental rate is charged at the time of rental.

3.3. Fuel Options. Travelers must decline all fuel option purchases and return the car with a full tank of gas. If circumstances prevent refueling a car, a detailed explanation must be included on the expense report.

3.4. Personal Automobiles. Travelers are permitted to use their personal automobiles for Seagate business, and Seagate will reimburse actual mileage, tolls, and parking fees. In the US, mileage will be reimbursed at the IRS standard mileage. In all other countries, mileage will be reimbursed at the local country rates. Contractor is responsible for ensuring that all travelers using personal automobiles have all proper licenses, insurance, and permits for the vehicles.

3.5. Transportation From Home to Airport. Travelers may use shuttle services for round trip transportation from a traveler's home to the airport if the cost is lower than the total cost of the mileage allowance plus airport parking. If a personal car is used to travel to the airport, the traveler must use long-term parking.

3.6. Use of Taxi Service. In the US, the cumulative daily expense for taxi service must not exceed the cost of renting a car.

3.7. Vehicle Violations and Fines. Seagate will not reimburse Contractor for any traffic fines, parking tickets, or any other vehicle violations. There are no exceptions to this requirement.

4. OVERNIGHT LODGING

4.1. Accommodations. If Seagate business requires the use of overnight lodging, Contractor must use moderately priced single room accommodations. The Seagate Corporate Travel Department has negotiated corporate hotel rates in most major cities. Contractor is expected to use these rates unless a lower rate is available to Contractor. If Contractor pays a higher rate than approved, then Seagate will not reimburse the difference in price. Preference for a hotel because of frequent traveler programs should never receive priority over cost savings for Seagate.

4.2. Cancellations. If any reservations must be canceled or changed, Contractor is responsible to ensure the reservation is canceled or changed in a timely fashion to avoid any "no show" charges. Seagate will not reimburse "no show" charges incurred due to failure to diligently cancel or change any reservation.

4.3. Use of Private Homes. In some instances, it may be convenient or necessary to use a private home of family or friends while traveling on Seagate business. Seagate will reimbursement up to US$50 per day for use of private homes.

5. MEALS

5.1. Travel Meals. Seagate will reimburse actual and reasonable meal expense when overnight travel is required to conduct Seagate business or when a one-day trip takes the traveler outside his or her normal work location. This includes breakfast if the traveler is required to leave home more than two hours earlier than normal, and dinner if the traveler cannot reasonably return home until two hours or more after normal working hours. The "reasonable" meal expense depends on the location traveled and prevailing exchange rate.

5.2. Business Meals and Entertainment. All meal and entertainment expenses (other than travel meals described above) must be approved by Seagate in advance. Any non-travel meal or expense that exceeds US$500 must be approved by a Senior VP, or above.

5.3. Receipts. Receipts are required for any single meal costing US$50 or more. If a receipt is not provided with the Expense Report, Seagate will not reimburse more than US$50. All receipts must be imprinted with the name of the establishment. The date and amount of the expense must also appear, but do not necessarily need to be imprinted.

5.4. Attendee List. An attendee list must be submitted with request for all meal and entertainment expense reimbursements.

6. EXPENSE REPORTS AND REIMBURSEMENT

6.1. Original Receipts. All receipts must be imprinted with the name of the establishment. The date and amount of the expense must appear, but do not necessarily need to be imprinted. If the original receipt is lost, the credit card statement can be used. The following documentation must be included with each expense report:

Airline tickets - the invoice, e-ticket, or the original passenger copy of the airline ticket, regardless of amount.

Automobile rental - the original rental receipt, regardless of amount.

Lodging - the original lodging receipt, regardless of amount.

Meals - the original meal receipt for any single meal costing US$50 or more.

Other expenses - for all other expenses, the original receipt must be provided for any single item costing US$50 or more.

6.2. Explanation of Exceptions. The expense report must include an explanation of any expenses for which no receipts are provided, such as meals less than US$50. The expense report must also include an explanation of any deviations of the policy, such as use of unauthorized travel agencies, lodging, or transportation providers.

6.3. Non-Reimbursable Expenses. Seagate will not reimburse the following items under any circumstances:

Flight insurance

Boarding fees for pets

Baby-sitting fees

Transportation between home and office on regular workdays

Traffic or parking tickets

Frequent traveler program fees

Additional travel or car rental insurance costs

Navigational systems in rental cars

Corporate card late fees

Airline club membership fees

In-room movies

Personal items lost, stolen, or damaged while traveling

Medications or prescriptions

Transportation, duties, taxes, and other fees associated with the shipment of personal effects.

7. CUSTOMS AND EXPORT CONTROL REQUIREMENTS

7.1. US Embargo List. All travelers are prohibited from traveling for business purposes to any country identified on the U.S. embargo list.

7.2. Customs Declarations. Government regulations may require the declaration of any merchandise, technical data, or currency that is exported and imported. Contractor is responsible for complying with all government regulations and declaring all carried items with the local customs authorities before departure and after arrival. In most cases, travelers arriving in the foreign country will be requested to complete a customs declaration form prior to entry. All travelers are required to properly declare all items (including technical data) being hand carried into any foreign country.

7.3. Violations. There are no exceptions to the customs and export control requirements. Any violation of government regulations may subject Contractor and the individual traveler to civil or criminal penalties, including fines, imprisonment, expulsion, forfeiture of goods, or loss of import and export licenses. Violations may also subject Contractor or Seagate to adverse publicity. Any violation will be considered an incurable and material breach of the contract with Seagate.